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Department of Education: Gaps in Federal Student Aid Contract Oversight and System Testing Need Immediate Attention
GAO-25-107396
Sep 09, 2025
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7 Open Recommendations
Agency Affected Recommendation Status
Department of Education The Secretary of Education should direct the Chief Operating Officer of FSA to take steps to improve its contract monitoring process to provide assurance that the contractor performs the work called for in the contract for FPS and develops a clear record of accountability for performance. (Recommendation 1)
Open
When we confirm whether the agency has taken action in response to this recommendation, we will provide updated information.
Department of Education The Secretary of Education should direct the Chief Operating Officer of FSA to establish a process to validate the contractor performance reports it receives. (Recommendation 2)
Open
When we confirm whether the agency has taken action in response to this recommendation, we will provide updated information.
Department of Education The Secretary of Education should direct the Chief Operating Officer of FSA to establish a process to ensure that assessments of contractor performance are documented in accordance with departmental guidance. (Recommendation 3)
Open
When we confirm whether the agency has taken action in response to this recommendation, we will provide updated information.
Department of Education The Secretary of Education should direct the Chief Operating Officer of FSA to take steps to ensure that all personnel performing program and project management activities and functions for the FPS contract obtain the appropriate FAC certifications. (Recommendation 4)
Open
When we confirm whether the agency has taken action in response to this recommendation, we will provide updated information.
Department of Education The Secretary of Education should direct the Chief Operating Officer of FSA to take steps to establish a process to ensure that all personnel performing contract oversight roles and responsibilities are provided with training related to the project management framework of the contract they are overseeing prior to contract execution. (Recommendation 5)
Open
When we confirm whether the agency has taken action in response to this recommendation, we will provide updated information.
Department of Education The Secretary of Education should direct the Chief Operating Officer of FSA to develop a standard or update its existing standard to include test case criteria for testing the FPS system that align with leading practices. (Recommendation 6)
Open
When we confirm whether the agency has taken action in response to this recommendation, we will provide updated information.

K–12 Education: DOD Needs to Assess Its Capacity to Provide Mental Health Services to Students
GAO-25-107247
May 14, 2025
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7 Open Recommendations
Agency Affected Recommendation Status
Department of Defense The Deputy Under Secretary of Defense for Personnel and Readiness should direct the DODEA Director to develop and disseminate guidance to schools for assigning standardized testing coordination responsibilities to school leaders. This guidance should discourage schools from relying on school counselors as standardized testing coordinators. (Recommendation 1)
Open
DOD partially concurred with this recommendation. DOD stated that it will direct DODEA to develop and disseminate guidance on assigning testing coordination responsibilities in a way that is mindful of school counselors' primary responsibilities. Our report noted that encouraging school leaders not to assign standardized testing coordination duties to school counselors, in line with the position of the American School Counselor Association, could help address some of DODEA's workload capacity issues. We continue to maintain that guidance to explicitly discourage assigning testing responsibilities to school counselors is warranted.
Department of Defense The Deputy Under Secretary of Defense for Personnel and Readiness should direct the DODEA Director to assess the capacity of its workforce to provide the continuum of behavioral supports indicated in its MTSS framework. This assessment should consider the capacity of school psychologists and school counselors. (Recommendation 2)
Open
DOD partially concurred with this recommendation. DOD said it has assessed school-level staffing to ensure responsibilities are appropriately positioned to support the strategic instructional needs of military-connected students, and noted that student support is not limited to school counselors and psychologists. Rather, it involves a comprehensive team of school nurses, school social workers, and other professionals committed to student success. We agree, and note that the recommendation does not preclude taking a broader approach as DOD outlines.
Department of Defense The Deputy Under Secretary of Defense for Personnel and Readiness should direct the DODEA Director to develop a plan based on the results of its workforce assessment to address any identified gaps in workforce capacity that could hinder the success of its MTSS initiative. (Recommendation 3)
Open
DOD partially concurred with this recommendation. DOD stated that the MTSS framework is meant to be adaptable to enable DOD to meet the ever-evolving needs of its schools and students. DOD also noted that the next phase of the MTSS rollout will focus on refining roles and responsibilities to ensure optimized resource allocation, and that MTSS requires cycles of continuous assessment. We agree that optimizing resource allocation is critical to the success of MTSS. However, DODEA has not yet assessed its capacity to implement all aspects of the MTSS initiative. We continue to believe that identifying any gaps in workforce capacity and developing a plan to address them will help DODEA align its staffing resources to meet students' needs and improve the success of its MTSS implementation.
Department of Defense The Deputy Under Secretary of Defense for Personnel and Readiness should direct the Director of Military Community Support Programs to evaluate the MFLC program's use in DODEA schools, seeking feedback from DODEA headquarters staff and school leaders, and develop a plan to address any areas of concern identified through its evaluation. (Recommendation 4)
Open
DOD agreed with this recommendation. DOD has an ongoing multi-step project to assess the MFLC program's use and effectiveness across all locations. The project includes locations where Child and Youth Behavioral (CYB)-MFLCs serve military children. DOD also noted a recent report commissioned by Military Community Support Programs that examined military-connected children in military child development centers, youth programs and schools with military populations served by CYB-MFLCs. We await further progress on this recommendation.
Department of Defense The Secretary of the Army should direct the Director of the Directorate of Prevention, Resilience, and Readiness to evaluate the ASACS program's use in DODEA schools, seeking feedback from DODEA headquarters staff and school leaders, and develop a plan to address any areas of concern identified through its evaluation. (Recommendation 5)
Open
DOD did not agree with this recommendation. DOD stated that, in the context of ongoing work to implement ASACS program guidance, ASACS staff in DODEA schools will collaborate with local DODEA school leaders and counselors for effective collaborative planning. Because this work is ongoing, DOD believes this recommendation is superfluous. While it is encouraging that the Army recognizes the value of collaboration, the ASACS program has not been evaluated for effectiveness in DODEA schools, and Army officials agreed that a formal program evaluation was needed. We continue to maintain that an evaluation of the ASACS program is necessary.
Department of Defense The Deputy Under Secretary of Defense for Personnel and Readiness should direct the Director of the Defense Health Agency to evaluate the School Behavioral Health program's use in DODEA schools, seeking feedback from DODEA headquarters staff and school leaders, and develop a plan to address any areas of concern identified through its evaluation. (Recommendation 6)
Open
DOD agreed with this recommendation. DOD stated that evaluating the program - including obtaining feedback from DODEA leaders and other stakeholders - is essential to program development, sustainment and efficiency. We await further progress on this recommendation.

Special Education: Improved Allocation of Resources Could Help DOD Education Activity Better Meet Students' Needs
GAO-25-107053
Apr 17, 2025
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5 Open Recommendations
Agency Affected Recommendation Status
Department of Defense The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness directs the DODEA Director to revise its special education staffing formulas to incorporate students' service minute requirements specified in IEPs among the factors it considers. (Recommendation 1)
Open
In March 2025, DOD partially concurred with this recommendation. In July 2025, DOD stated that it no longer concurs with this recommendation. Specifically, it said that DODEA reviewed its staff-to-student ratios in special education classrooms and found them to be lower than national averages. The agency also said that basing staffing allocations on a "simple tally" of IEP service minutes is operationally unfeasible. We agree that only using IEP service minutes to determine staffing allocations would not be appropriate, and we did not recommend doing so. However, required IEP service minutes provide critical information on the frequency and duration of services required to meet individual student's' needs. Further, they can vary widely among students. Moreover, at 13 of the 14 DODEA schools we visited-located in the three largest DODEA school districts, which collectively educate 50 percent of all DODEA students receiving special education services-school staff told us that basing staffing formulas solely on student headcounts does not allow staff to provide the required number of service outlined in students' IEPs. This is particularly significant, given that at all 14 schools we visited, DODEA school staff cited special education staffing shortages-and resulting heavy workloads-as an obstacle to educating students with disabilities. Moreover, they told us that staffing shortages impact the quality and frequency of services for students receiving special education. By allocating staff in a way that considers students' legally required IEP minutes, DODEA could better ensure that students receive the support to which they are entitled to make progress towards their educational goals.
Department of Defense The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness directs the DODEA Director to ensure that any special education paraeducators who work with students who may need behavioral supports receive crisis training. (Recommendation 2)
Open
DOD partially concurred with this recommendation. In July 2025, DODEA stated that it expanded its crisis training contract for all staff, beginning in school year 2025-2026. Additionally, DODEA said that it is implementing a centralized training completion tracking system to ensure consistent, agency-wide compliance and support for students and staff, and expects to complete these actions in January 2026. We will continue to monitor the agency's efforts in this area.
Department of Defense The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness directs the DODEA Director to provide supplemental instructional materials to special education teachers agencywide to help them adapt the general education curriculum for students with IEPs. (Recommendation 3)
Open
DOD partially concurred with this recommendation. In July 2025, DODEA stated that to enhance instructional quality for students with disabilities, it is undertaking an inventory of the agency's existing instructional resources, as well as launching professional learning modules in fall 2025 focused on specially designed instruction and evidence-based strategies in reading and math. Additionally, DODEA stated that prior to GAO's review, DODEA allocated funding for targeted reading materials in grades 3-5 and anticipated completing these corrective actions in June 2026. DODEA stated it would not pursue any singular, centralized purchases of supplemental instructional materials, because doing so may not account for the individualized nature of student needs and would require significant investment. We agree. However, there are other ways that access to supplemental materials could be made available agencywide. For example, DODEA could acquire special education instructional materials available for specific curriculum for teachers to tailor to students' individual needs. Teachers also suggested having a specialist dedicated to helping them find instructional tools to meet individual student needs. The fact remains that DODEA regional, district, and school-level staff representing the majority of DODEA students expressed significant concerns about the lack of access agencywide to instructional materials for tailoring special education to students' needs, noting that staff in some districts and regions had access while others did not. Further, special education teachers at 10 of the 14 schools we visited told us that the general curriculum materials they have do not meet their students' needs. We maintain that agencywide access to appropriate supplemental instructional materials would better help DODEA teachers to support their students while allowing them to tailor instructional materials to students' unique needs. Additionally, not having to constantly "reinvent the wheel", as some educators described it, it could allow teachers more time to teach and may improve the quality of support students receive. We will continue to monitor DODEA's efforts in this area.
Department of Defense The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness directs the DODEA Director to make more specialized reading interventions accessible across all DODEA locations to students with specific learning disabilities, including dyslexia, that impact their ability to read. (Recommendation 4)
Open
DOD partially concurred with this recommendation. In July 2025, DODEA stated that it is strategically investing in targeted reading interventions for grades 3-5 to address critical literacy development needs. DODEA stated that it anticipates completing this action in October 2025, and that this effort prioritizes students with disabilities during a pivotal academic transition period, while supporting DODEA's goal of fiscally responsible procurement. We agree this initiative will widen access to specialized reading interventions for students in grades 3-5. However, regional and district officials representing nearly 65 percent of DODEA students with specific learning disabilities, such as dyslexia, told us that it can be difficult to obtain specific reading interventions for dyslexia in their locations. While provided targeted reading interventions for grades 3-5 will help, it will not address the fact that some schools and districts have access to more specialized reading interventions while others do not. An approach that makes specialized reading interventions accessible across all locations would help ensure that students with reading-related disabilities receive the same opportunities to learn to read, regardless of which DODEA school they attend. We will continue to monitor DODEA's progress on these efforts.
Department of Defense The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness directs the DODEA Director to communicate its timeframes for its new procedural guidance on special education and what resources staff should use to interpret the DOD policy while that guidance is being developed. (Recommendation 5)
Open
DOD partially concurred with this recommendation. In July 2025, DODEA stated that it is launching a three-phased rollout of special education policies beginning in school year 2025-2026 that it expects to complete in October 2025. This will include updated procedures, professional learning and job aides for educators, and parent resources. DODEA said that it will communicate expected timeframes for its updated policies through weekly packets, and indicate that updated policies replace all previous guidance, as it becomes available. We still maintain that communicating what resources staff should use while DODEA updates policy would be helpful for staff providing special education. This is especially important since the policy updates will not be complete at the start of the school year, and school staff we spoke with said that existing policy is not clear or detailed enough to implement without additional guidance. We will continue to monitor DODEA's progress on these efforts.

Department of Education: Preliminary Results Show Strong Leadership Needed to Address Serious Student Aid System Weaknesses
GAO-24-107783
Sep 24, 2024
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5 Open Recommendations
3 Priority
Agency Affected Recommendation Status
Department of Education The Secretary of Education should direct the Chief Operating Officer of FSA to (1) expeditiously develop a plan that tailors the agency's guidance on identifying and managing requirements to fit its current incremental deployment approach and (2) implement the plan thereafter. (Recommendation 1)
Open
In April 2025, FSA stated that the Office of Student Aid Program Management, the office responsible for FAFSA development, uses modern tools to manage incremental deployment and provide visibility into progress of development over time. They did not further discuss any actions they have taken or plan to take to develop a plan that would document their use of the tools to manage development of the FAFSA form. We will continue to monitor FSA's actions to implement this recommendation.
Department of Education
Priority Rec.
The Secretary of Education should direct the Chief Operating Officer of FSA to (1) expeditiously develop a plan that tailors the agency's guidance on system testing to fit its current incremental deployment approach and (2) implement the plan thereafter. (Recommendation 2)
Open
In April 2025, FSA stated that the Office of Student Aid Program Management has a detailed, layered testing plan to ensure confidence in the FAFSA. We will update the status of the recommendation once FSA provides the plan and we are able to evaluate whether it addresses the recommendation.
Department of Education
Priority Rec.
The Secretary of Education should direct the Chief Operating Officer of FSA to expeditiously (1) develop an FSA policy on standards for IV&V independence and (2) ensure that FPS IV&V agents meet those standards. In developing the policy, FSA should define the degree of technical, managerial, and financial independence required of the personnel or agents performing IV&V. (Recommendation 3)
Open
In April 2025, FSA stated that it has hired a new digital services team to provide better oversight of development. These team members, and others, according to the agency, are the primary technical product managers and engineers capable of reviewing code and ensuring competent delivery. However, FSA did not comment on the actions they have taken or plan to take to develop a policy on IV&V independence standards. We will continue to monitor FSA's actions to implement this recommendation.
Department of Education The Secretary of Education should direct the Chief Operating Officer of FSA to expeditiously (1) develop an FSA policy requiring that projects determine and document the appropriate scope of IV&V efforts and (2) ensure that the FPS project follows this policy. In developing the policy, FSA should require that projects consider IV&V activities across the acquisition lifecycle. (Recommendation 4)
Open
In April 2025, FSA stated that all systems that impact the FAFSA form are reviewed by internal technical talent before release and go through the technical release management process to ensure high-quality deployment. However, the agency did not comment on the actions they have taken or plan to take to develop a policy requiring that projects determine and document the appropriate scope of IV&V efforts. We will continue to monitor FSA's actions to implement this recommendation.
Department of Education
Priority Rec.
The Secretary of Education should expeditiously (1) assess the role of the department's and FSA's CIOs in the continuing development of FPS, and (2) based on that assessment, develop and implement a plan for providing the department's CIO with a significant role in the governance and oversight of FPS while clarifying the responsibilities between the departmental and agency CIO. (Recommendation 6)
Open
In September 2024, FSA announced that the agency had begun recruiting for a new Chief Technology Officer (CTO) that would replace FSA's Chief Information Officer (CIO) role. According to the agency, this would ensure that there is only one CIO position in the Department of Education (Education). According to FSA, both the Education CIO and the FSA CTO play a crucial role in the ongoing governance and oversight of the FAFSA through frequent engagement with the Executive Director for Student Aid Program Management. FSA did not comment on the actions it has or planned to take to develop and implement a plan for providing the department's CIO with a significant role in the governance and oversight of FPS. We will continue to evaluate the department's progress in implementing this recommendation.
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